Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
This proceeding involves a deficiency in income tax for 1947 in the amount of $6,217.05. The sole issue is whether an amount received by petitioner in the taxable year from Touche, Niven & Co., is ordinary income or capital gain. The taxpayer's return for the calendar year 1947 was filed with the collector of internal revenue for the second district of New York. This case was consolidated for hearing...
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